Personal Data Processing Policy of LEA LINSTER
The present personal data processing policy is developed in accordance with the EU Regulation (EC) 2016/679 of the European Parliamant and the Council of 27 April 2016, entered into force on May 25th 2018.
The EU Regulation 2016/679 and the personal data processing policy of LEA LINSTER only applies to the processing of personal data relating to natural persons, excluding legal persons.
The controller is the limited liability company LEA LINSTER SARL, established and having its registered office in L-5752 FRISANGE, 17, rue de Luxembourg, represented by its currently acting manager (hereinafter referred to as “LEA LINSTER”).
Within LEA LINSTER, Mr. Louis LINSTER (email@example.com) has been appointed Data Protection Officer and deals in particular with the implentation of the personal data processing policy.
2) Collection and processing of personal data (PD), means of processing and purpose of processing
a) If you are entering into a contractual relationship with LEA LINSTER, the following PD will always be collected:
- Private and professional adress
- E-mail adress
- Phone and mobile phone number
b) According to the nature of the contractual relationship, the following PD may be collected by LEA LINSTER:
- Date of birth
- Personal status
- and every information necessary for the fulfillment of the contractual obligations of LEA LINSTER
We are collecting and processing this data in order:
- To help us identify you as our client and to provide you with information,
- To communicate with you,
- To assure the follow-up of bookings and orders (gift-vouchers, cooking classes,…),
- To assure the management of customer files,
- To cope with administrative and organisational requirements, e.g. processing of claims, control of accounting information and credit card payments, fraud detection,...
- To issue our invoices, and in order
- If need be, to ensure our debt recovery.
The data is used by LEA LINSTER, its associates and employees in the context of the contractual relationship you entered into with LEA LINSTER.
Depending on the nature of the contractual relationship you maintain with LEA LINSTER, your PD may however be passed in particular to subcontractors (especially in the context of the management of reservations through online booking services and the management of LEA LINSTER’s payment services), suppliers, public authorities,… and to any other person whose collaboration may be necessary and/or helpful in order to fulfil LEA LINSTER’s contractual and legal obligations.
3) Location of data storage
Your identification data (name, surname, if necessary, e-mail address, telephone number) will be stored in the client inventory of LEA LINSTER.
Your PD relating to your contractual relationship with LEA LINSTER (in particular your identification data and your orders’ details) will be stored particularly, entirely or partially, in a computer file, but can also be stored, entirely or partially, in a paper file.
4) Duration of the data processing
LEA LINSTER will store your PD for the full duration of the contractual relationship, increased by the duration during which LEA LINSTER may be held liable or as long as it may be required by any other legal or regulatory obligation or as long as the storage may be required in the purposes for purposes of proof in the context of litigation.
5) Your rights
a) Right of information
You have the right to know who is processing your data and why and for which purpose it is processed.
In case of a security breach resulting in an infringement of PD that may lead to a significant risk for your rights and freedoms, the controller is obliged to inform you without undue delay.
b) Right of access
Upon request, the controller is obliged to communicate the entirety of the PD relating to you.
c) Right to rectification
You have the right to request the controller to rectify your PD.
d) Right to erasure (‘right to be forgotten’)
If there are no longer legitimate grounds for the processing of the PD, the controller is obliged to erase your PD upon your request without delay within a reasonable period of time.
e) Right to data portability
You have the right to receive the data you have provided to LEA LINSTER in a structured, commonly used and machine-readable format and the right to transmit those data to a third party, provided that the processing is carried out by automated means and based on your consent or on a contract between you and LEA LINSTER.
f) Right to object
You have the right to object at any time to processing of your PD for the future. Your objection only applies for the future without any retroactive effect. In case of opposition, your PD will immediately be deleted.
However, your right to object shall not apply when the processing is expressly laid down by law.
g) Right to restriction of processing
You have the right to request the restriction of processing of your PD:
- If you contest the accuracy of a personal data, for a period enabling the controller to verify the accuracy of the personal data,
- If the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead,
- If you require the data for the establishment, exercise or defence of legal claims.
When processing has been restricted, your PD shall no longer be processed.
h) Right to complain
You have the right to exercise your rights before the controller.
If your complaint remained unanswered, you have the right to lodge a complaint with the CNPD (www.cnpd.lu).
Furthermore, you have the right to seize a court.
The present personal data processing policy may be modified at any time and may never be deemed a client’s vested right.
Luxembourg, October … 2019